LR-N24-0056, Response to Request for Additional Information Associated with License Amendment Request - Revise Hope Creek Generating Station Technical Specification to Change Surveillance Intervals to Accommodate a 24-Month Fuel Cycle
| ML24271A138 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/26/2024 |
| From: | Denight R Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N24-0056, LAR H24-01 | |
| Download: ML24271A138 (1) | |
Text
Robert DeNight HCGS Site Vice President, PSEG Nuclear PO Box 236 Hancocks Bridge, New Jersey 08038-0221 856-339-5303 Robert.denightjr@pseg.com 10 CFR 50.90 LR-N24-0056 LAR H24-01 September 26, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354
Subject:
Response to Request for Additional Information Associated with License Amendment Request - Revise Hope Creek Generating Station Technical Specification to Change Surveillance Intervals to Accommodate a 24-Month Fuel Cycle
References:
- 1.
PSEG letter to NRC, License Amendment Request - Revise Hope Creek Generating Station Technical Specification to Change Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, dated May 20, 2024 (ADAMS Accession No. ML24141A136)
- 2.
NRC email to PSEG, Hope Creek - Final EEEB RAI regarding Amendment to Revise TS to Change Surveillance Interval to Accommodate 24-Month Fuel Cycle (EPID: L-2024-LLA-0065), dated September 9, 2024 (ADAMS Accession No. ML24253A194)
In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request (LAR) to Renewed Facility Operating License (RFOL) No. NPF-57 for Hope Creek Generating Station (HCGS) to implement a 24 Month Fuel Cycle (24MFC).
In the Reference 2 email, the NRC provided PSEG a request for additional information (RAI) to support the NRC staffs detailed technical review of the Reference 1 submittal. The attachment to this letter contains the responses to the RAI questions contained in Reference 2.
PSEG has determined that the information provided in this submittal does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
There are no regulatory commitments contained in this letter. If there are any questions or if additional information is needed, please contact Mr. Brian Thomas at brian.thomas@pseg.com.
LR-N24-0056 Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on, _
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Respectfully, Robert W. DeNight Site Vice President (Date)
Hope Creek Generating Station 10 CFR 50.90 LAR H24-01
Attachment:
Response to Hope Creek - Final EEEB RAI regarding Amendment to Revise TS to Change Surveillance Interval to Accommodate 24-Month Fuel Cycle (EPID: L-2024-LLA-0065) cc:
Administrator, Region I, NRC NRC Project Manager, Hope Creek NRC Senior Resident Inspector, Hope Creek Manager, NJBNE
Attachment LR-N24-0056 LAR H24-01 Response to Hope Creek - Final EEEB RAI regarding Amendment to Revise TS to Change Surveillance Interval to Accommodate 24-Month Fuel Cycle (EPID: L-2024-LLA-0065)
Attachment LR-N24-0056 LAR H24-01 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO CHANGE SURVEILLANCE INTERVALS TO ACCOMMODATE 24-MONTH FUEL CYCLE (EPID L-2024-LLA-0065)
By letter dated May 20, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24141A136), Public Service Enterprise Group Nuclear LLC (PSEG, the licensee) requested to amend the Technical Specifications (TSs) for Hope Creek Generating Station (Hope Creek) to implement a 24 Month Fuel Cycle (24MFC). Hope Creeks license amendment request (LAR) would revise certain Surveillance Requirements (SRs) intervals from 18 months to 24 months. The proposed SR intervals are in accordance with NRC Generic Letter (GL) 91-04.
The following regulatory requirements and General Design Criteria are applicable to the Hope Creek electrical power systems.
Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36(c)(3), "Surveillance requirements," state that surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
General Design Criterion (GDC) 17, Electric power systems, of Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, states in part that an onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.
GDC 18, Inspection and Testing of Electric Power Systems, requires that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing.
Guidance:
Generic Letter (GL) 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, provides, in part, guidance on preparation of a license amendment request for changes in surveillance intervals to accommodate a 24-month fuel cycle.
Attachment LR-N24-0056 LAR H24-01 The NRC staff has determined that the following information is needed for the staff to complete the review and to reach the regulatory safety finding.
Request Additional Information (RAI)
RAI #1 In the LAR, the licensee stated that the proposed change follows the guidance of NRC Generic Letter (GL) 91-04 to increase the SR intervals from 18 months to 24 months.
For non-calibration SRs, GL 91-04 recommends, in part, that the licensees should perform the following to support surveillance intervals to accommodate a 24-month fuel cycle:
a)
Evaluate the effect on safety of the change in surveillance intervals to support a conclusion that the effect on safety is small.
b)
Confirm that historical maintenance and surveillance data do not invalidate the conclusion that the effect on safety is small.
c)
Confirm that the performance of surveillances at the bounding surveillance interval limit provided to accommodate a 24-month fuel cycle would not invalidate any assumption in the plant licensing basis.
For Recommendation (a) above, LAR Section 4.1.1, Non-Calibration Change, states, in part:
Each non-calibration SR frequency being changed has been evaluated with respect to the effect on plant safety. The methodology utilized to justify the conclusion that extending the testing interval has a minimal effect on safety was based on the fact that the function/feature is:
(1) Tested on a more frequent basis during the operating cycle by other plant programs; (2) Designed to have redundant counterparts or be single failure proof; or (3) Highly reliable.
A summary of the evaluation of the effect on safety for each non-calibration SR Frequency being changed is presented in Attachment 3.
The staff notes that Attachment 3, Section 2.1.1 of the LAR further describes the evaluation to justify the conclusion that changing the non-calibration SR intervals from an 18-month to a 24-month frequency has a minimal effect on safety. However, the LAR does not specify the more-frequent testing (Item (1) above). For each of SRs 4.8.1.1.2, 4.8.4.1, and 4.8.4.2.1 please specify the more frequent testing(s) to support the justification. For each such test, the response to this RAI should include the type of test and what surveillance or program it is under.
Response to RAI #1:
As cited in the RAI, the three criteria utilized to justify minimal effect on safety do not all need to be satisfied to make this determination. However, consistent with other precedent, such as Fermi 21, additional justification is provided below based on more frequent testing.
1 ADAMS Accession Number ML19312A110
Attachment LR-N24-0056 LAR H24-01 SR 4.8.1.1.2.k and SR 4.8.1.1.2.h (Items 2, 3, 4, 5, 6, 7, 9, 10, and 11) are required to demonstrate operability of the diesel generators (DGs). The SR 4.8.1.1.2.k periodicity is proposed to be increased from 18 months to 24 months, and the SR 4.8.1.1.2.h periodicity is proposed to be increased from 36 months to 48 months. The following SRs are performed on a more frequent basis to demonstrate DG operability:
SR 4.8.1.1.2.a is performed every 31 days on a Staggered Test Basis in accordance with the Surveillance Frequency Control Program (SFCP) by:
- 1. Verifying the fuel level in the fuel oil day tank.
- 2. Verifying the fuel level in the fuel oil storage tank.
- 3. Verifying the fuel transfer pump starts and transfers fuel from the storage system to the fuel oil day tank.
- 4. Verifying each diesel generator starts from standby conditions and achieves steady state voltage 3828 and 4580 volts and frequency of 60 +/- 1.2 Hz.
- 5. Verifying the diesel generator is synchronized, loaded to between 4000 and 4400 kw and operates with this load for at least 60 minutes.
- 6. Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.
- 7. Verifying the pressure in all diesel generator air start receivers to be greater than or equal to 325 psig.
- 8. Verifying the lube oil pressure, temperature and differential pressure across the lube oil filters to be within manufacturer's specifications.
SR 4.8.1.1.2.b is performed every 31 days in accordance with the SFCP by visually examining a sample of lube oil from the diesel engine to verify absence of water.
SR 4.8.1.1.2.c is performed every 31 days in accordance with the SFCP and after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated water from the fuel oil day tank.
SR 4.8.1.1.2.d is performed every 92 days in accordance with the SFCP by removing accumulated water from the fuel oil storage tanks.
SR 4.8.1.1.2.e is performed every 9 months in accordance with the SFCP by performing a functional test on the emergency load sequencer to verify operability.
SR 4.8.1.1.2.f is performed in accordance with the surveillance interval specified in the Diesel Fuel Oil Testing Program and prior to the addition of new fuel oil to the storage tank, samples shall be taken to verify fuel oil quality. Sampling and testing of new and stored fuel oil shall be in accordance with the Diesel Fuel Oil Testing Program contained in Specification 6.8.4.e. TS 6.8.4.e.b is performed 31 days following sampling and addition to storage tanks and TS 6.8.4.e.c is performed every 92 days.
SR 4.8.1.1.2.g is performed every 184 days in accordance with the SFCP by verifying each diesel generator starts from standby conditions and achieves 3950 volts and 58.8 Hz in 10 seconds after receipt of the start signal, and subsequently achieves steady state voltage 3828 and 4580 volts and frequency of 60 +/- 1.2 Hz.
Attachment LR-N24-0056 LAR H24-01 As stated in Reference 1 Attachment 3, the impact, if any, on system availability is minimal from the proposed changes to a 24 month and 48 month testing frequency. Based on the inherent system and component reliability as shown by the failure history provided in Reference 1, and supplemented by the information provided above, the impact of this change on safety, if any, is small.
SR 4.8.4.1.a.2 is required to demonstrate each of the lower voltage primary containment penetration conductor overcurrent protective devices shown in Table 3.8.4.1-1 are operable.
The SR periodicity is proposed to be extended from 18 months to 24 months. There is no other periodic testing associated with these devices. As stated in Reference 1 Attachment 3, the impact, if any, on system availability is minimal from the proposed change to a 24 month testing frequency. Based on the inherent system and component reliability as shown by the failure history provided in Reference 1 Attachment 3, the impact of this change on safety, if any, is small.
SR 4.8.4.2.1.a (Items 2 and 3) are required to demonstrate the thermal overload protection bypass circuit for each motor operated valve required to have thermal overload protection are operable. The SR periodicity is proposed to be extended from 18 months to 24 months. There is no other periodic testing associated with these devices. As stated in Reference 1 Attachment 3, the impact, if any, on system availability is minimal from the proposed change to a 24 month testing frequency. Based on the inherent system and component reliability as shown by the failure history provided in Reference 1 Attachment 3, the impact of this change on safety, if any, is small.
RAI #2 Hope Creek TS 3/4.8.1.1.2.k.2 states, in part:
-OR-Operate the diesel generator between 4000 kW and 4400 kW for two hours. Within 5 minutes of shutting down the diesel generator, verify each diesel generator starts and achieves 3950 volts and 58.8 Hz in 10 seconds after receipt of the start signal, and subsequently achieves steady state voltage 3828 and 4580 volts and frequency of 60 +/-
1.2 Hz. This test shall continue for at least five minutes.
LAR Attachment 3, Pages 30 and 31 of 70, state (bold emphasize added):
-OR-Operate the diesel generator between 4000 kW and 4400 kW for two hours. Within 5 minutes of shutting down the diesel generator, verify each diesel generator starts and achieves 3950 volts and 58.8 Hz in 10 seconds after receipt of the start signal, and subsequently achieves steady state voltage 3828 and 4580 volts and frequency of 60 +/-
1.2 Hz. This test shall continue for at least five minutes.
Please explain the discrepancy between the TS and LAR ( 10 seconds and 10 seconds, respectively) with regards to the time required to verify each diesel generator starts and achieves 3950 volts and 58.8 Hz after receipt of its start signal.
Attachment LR-N24-0056 LAR H24-01 Response to RAI #2:
PSEG acknowledges the typographical error in 10 seconds and revises this to read 10 seconds with this RAI response.